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Understanding HAZWOPER Facility Operations

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Understanding HAZWOPER Facility Operations

Welcome to this training program on HAZWOPER Facility Operations.

  • HAZWOPER stands for Hazardous Waste Operations and Emergency Response. It is a regulatory standard that refers to five types of hazardous waste operations conducted in the United States. The standard contains the safety requirements employers must meet in order to conduct these operations.
  • OSHA issued the HAZWOPER Standard, 29 CFR 1910.120(e), in 1986 to codify the safety and health requirements companies would have to meet in order to perform hazardous waste cleanups or to respond to emergencies.
  • As we’ll discuss, extensive training is necessary to ensure compliance with the HAZWOPER standard.

Goals

By the end of the training session, trainees will:

  • Be aware of the safety, environmental, and health threats posed by hazardous wastes at the worksite.
  • Know where to find additional information about hazardous wastes and other materials.
  • Understand the medical surveillance requirements in force at the worksite and know why they are important.
  • Understand and be prepared to consistently follow the work practices and procedures designed to eliminate or reduce risks of an accident or incident.
  • Recognize the engineering controls deployed at the worksite to help ensure safety.
  • And understand the importance of, and be prepared to properly use, personal protective equipment (PPE).

Hazardous Waste

  • Before we start working through these objectives, however, let’s back up for a moment. We’ve all heard the term “hazardous waste,” but what is it? A hazardous waste is waste material that poses threats to public and personal health or the environment. A hazardous waste usually exhibits at least one of these characteristics:

– Carcinogenic, or cancer-causing,

– Ignitable, or flammable,

– Explosive,

– Oxidizing,

– Corrosive,

– Toxic, and

– Radioactive.

  • U.S. environmental laws and regulations describe a “hazardous waste” as a waste that has the potential to cause, or significantly contribute to, an increase in mortality or an increase in serious illness; or
  • Poses a substantial hazard to human health or the environment when improperly treated, stored, transported, disposed of, or managed. 40 CFR 261.3 and 49 CFR 171.8 define hazardous wastes.

HAZWOPER Operations

The HAZWOPER standard applies to five types of operations:

  • Hazardous waste site cleanup operations;
  • Corrective actions involving cleanup operations at Resource Conservation and Recovery Act (RCRA)-regulated sites;
  • Voluntary cleanup operations at sites recognized by federal, state, or local governmental bodies as uncontrolled hazardous waste sites;
  • Operations involving hazardous waste at treatment, storage, and disposal facilities, or TSDFs, licensed under RCRA; and
  • Emergency response operations for release or substantial threats of release of hazardous substances.

Training Requirements

The HAZWOPER standard sets specific training requirements for personnel working on hazardous waste sites, performing TSDF-related operations, or performing emergency response to releases of hazardous materials. The training requirements for hazardous waste site personnel include:

  • General hazardous waste site workers must have a minimum of 40 hours of off-site instruction and at least 3 days of field experience under the direct supervision of a trained, experienced supervisor.
  • A minimum of 24 hours of off-site training and 1day of field experience are required for workers occasionally on-site for a specific or limited task. Workers regularly on-site who work in areas with exposures below permissible limits and where there is found to be no health hazards or possibility of an emergency related to hazardous wastes also receive this level of training.
  • Managers and supervisors of hazardous waste sites must have 40 hours of initial training and 3 days of supervised field experience plus at least 8 additional hours of specialized training.
  • And, 8 hours of refresher training are required annually for all workers.

Emergency response personnel and hazardous waste technicians require additional training.

Employees are not permitted to participate in or supervise field activities until they’ve been trained to perform their job function and to meet their responsibilities.

Compliance Areas

The HAZWOPER standard defines and requires compliance in several specific areas:

  • Site characterization and analysis;
  • Site control;
  • Training;
  • Medical surveillance;
  • Engineering controls, work practices, and PPE; and
  • Monitoring.

We’ll touch on each of these in this training session.

Compliance Areas (cont.)

The HAZWOPER standard also requires compliance in:

  • Informational programs,
  • Material handling,
  • Decontamination,
  • Emergency response,
  • Illumination, and
  • Sanitation.

Overlapping Rules

Other related or overlapping rules and regulations may apply to workers who work with or around hazardous materials. These include:

  • Environmental Protection Agency, or EPA, Laws and Regulations;
  • The Resource Conservation and Recovery Act, or RCRA;
  • The Comprehensive Environmental Response Compensation and Liability Act, or CERCLA;
  • Superfund Amendments and Reauthorization Act, or SARA Title III;
  • Toxic Substances Control Act, or TSCA; and
  • Department of Transportation, or DOT, guidelines.

Hazard Information

  • Workers at hazardous waste sites often need to handle toxic or reactive materials. The OSHA Hazard Communication Standard (29 CFR 1910.1200) requires employers to communicate the hazards associated with the handling of such hazardous materials to employees involved in operations using those materials.
  • A Material Safety Data Sheet, or MSDS, is used to convey this information. Manufacturers provide MSDSs for all hazardous ingredients. An MSDS lists:

– The material’s ingredients/composition;

– Its physical and chemical characteristics;

– Potential for hazards, such as fire, explosion, or reaction;

– Possible health hazards and symptoms;

– How the materials can get into the body, through skin contact, inhalation, or swallowing; exposure limits;

– How to handle the material safely, through handling procedures and the use of PPE; and

– Emergency response and first aid.

Employees must always read the MSDS carefully to know what they’re working with and how to handle the material safely.

  • Similar information is found on the product warning label on the container.

Hazard Information (cont.)

  • In the case of hazardous waste, a manifest accompanies each container of hazardous waste from the time it is loaded for transport to the time it is disposed of (or, from “cradle to grave”). The manifest identifies the material; the quantity being shipped; and the generator, transporter, and receiver. Every outgoing shipment of hazardous waste must have a manifest. When the shipment arrives at its final destination, a copy must be sent back to the generator so they know the waste arrived safely at its proper destination.

Hazard Recognition

Reading documents such as manifests, MSDSs, and warning labels is only one way to recognize the hazardous materials around you at the worksite. You should also:

  • Pay careful attention to signs, tags, and labels attached to any materials or containers.
  • Carefully observe your surroundings and investigate any unknown items before you come into contact with them.
  • Increase your knowledge by getting all the health and safety training you can.
  • Be aware of hazards identified through processes such as site characterization.
  • And, rely on data from equipment such as air monitoring equipment.

We’ll discuss several of these methods as this training session continues.

Hazard Types

You can begin protecting yourself and others by becoming more aware of the types of hazards posed by materials at the worksite. Common types of workplace hazards include:

  • Chemical property;
  • Physical, such as electrical; cold or heat stress; or slips, trips and falls, among many others;
  • Radiation; and
  • Biological

Chemical Property Hazard

Chemical property hazards include:

  • Fire hazards, such as combustibility and flammability;
  • Explosive hazards, often from gases or vapors;
  • Toxicity;
  • Corrosivity; and
  • Hazards due to chemical reactivity.

Chemical Property Hazards

  • When working with, contacting, storing, or transporting a potentially hazardous material, it is important to know the physical properties of the material that determine the type and degree of the hazard. These properties include:

– Solubility,

– Density/specific gravity,

– Vapor density,

– Vapor pressure,

– Boiling point,

– Melting point, and

– Flashpoint.

These properties can be found in information sources, including the MSDS.

Physical Hazards

Physical hazards may include:

  • Kinetic or mechanical hazards. These range from having a finger pinched by some equipment to slipping on a wet floor or being struck by a vehicle or fallen object;
  • Thermal hazards, such as fires, explosions, or hot environments;
  • Electrical hazards, including faulty wiring or downed power lines; and
  • Acoustic hazards from sources such as explosions and loud machinery. Physical hazards can be compounded by the presence of hazardous materials, such as hazardous wastes. For instance, an electrical fire in a hazardous waste storage area can lead to an uncontrolled toxic release and a public health emergency.

Radiation Hazards

Radioactive materials present additional risks, including potential genetic mutations and cancer. There are three forms of ionizing radiation: alpha particles, beta particles, and gamma rays.

All of these forms are serious health hazards. For protection from radiation, one should:

  • Keep the amount of time exposed as short as possible.
  • Maintain distance; keep as far away as possible.
  • Monitor the area to ensure protective barriers or devices are working properly.
  • And, use protective barriers and PPE specifically designed for the kinds of radioactive materials present.

Biological Hazards

The biological hazards that hazardous waste site workers may encounter include:

  • Bites or stings,
  • Contact with plants, and
  • Exposure to microbes.

Additional Hazards

Many other types of hazards may exist at the worksite, including:

  • Harmful dusts, fumes, mists, and gasses;
  • Optical radiation from welding, or the lack of sufficient illumination;
  • Excessive heat or cold;
  • Rain, snow, or sleet, because some materials are sensitive to moisture;
  • Lack of oxygen; and
  • A fall from heights.

Again, the presence of hazardous waste may complicate or heighten the risks. As an example, cold storage of certain materials may present hazards such as frostbite or hypothermia to workers.

Atmospheric Hazards

Atmospheric hazards are of particular concern at hazardous waste sites since, at times, these wastes may contribute to the hazard. Atmospheric hazards include:

  • Oxygen deficiency,
  • Explosive atmospheres,
  • Toxic atmospheres, and
  • Radioactivity, which we’ve already briefly discussed.

Hazard Sources

The sources of hazards are myriad at any workplace. Look around you and consider or list the sources that you see. The list on this slide shows just some of the examples you may find.

  • Chemical properties,
  • Heat sources,
  • Noise or light sources,
  • Electrical or energy sources,
  • Equipment, or
  • Work surfaces.

Brainstorm with trainees about all the potential hazards at the worksite. Discuss any impact these may have on hazardous wastes or other materials.

Jeopardy

Now that you are in an active mode, let’s continue with a game to review the material we’ve covered so far. You are probably familiar with the television game show Jeopardy. This game is similar to that one, in that you will be given the “answer” and asked to compose the proper “question.” Let’s give it a try with the “answers” on the slide.

  1. Hazardous Waste Operations and Emergency Response—What does “HAZWOPER” stand for?
  2. Wastes that pose serious health or environmental threats—What are hazardous wastes?
  3. Material Safety Data Sheets—What is a document that explains the hazards and properties of a material?

Jeopardy

Now that you are in an active mode, let’s continue with a game to review the material we’ve covered so far. You are probably familiar with the television game show Jeopardy. This game is similar to that one, in that you will be given the “answer” and asked to compose the proper “question.” Let’s give it a try with the “answers” on the slide.

  1. Hazardous Waste Operations and Emergency Response—What does “HAZWOPER” stand for?
  2. Wastes that pose serious health or environmental threats—What are hazardous wastes?
  3. Material Safety Data Sheets—What is a document that explains the hazards and properties of a material?

Jeopardy

Continue with the Jeopardy game:

  1. Toxicity, Corrosivity, Reactivity—What are types of chemical properties?
  2. Oxygen deficiency, explosive atmosphere—What are types of hazardous environments?
  3. Document that accompanies hazardous waste “from cradle to grave”—What is a hazardous waste manifest?

How did you do?

Questions?

At this point, be sure you understand:

  • What HAZWOPER is,
  • HAZWOPER training requirements,
  • HAZWOPER compliance issues, and
  • The hazards associated with HAZWOPER.

Toxins Entering The Body

Before we begin discussing how to protect yourself from the threats of hazardous wastes, let’s look a little more closely at the dangers posed by substances that pose health hazards, such as toxic materials. Toxins are transported into the body by:

  • Inhalation,
  • Skin absorption,
  • Ocular, (or through the eyes),
  • Entry through wounds or orifices, and
  • Ingestion.

Exposure Limits

Although some chemicals may be more harmful than others, the concentration of the material and the duration of expose can make a big difference. To prevent harmful effects, it is important to determine not only the identity of the materials involved, but also the type and extent of exposure, the possible symptoms of overexposure and, most important, the exposure levels that are considered safe for each material encountered.

A great deal of information is available about the toxic properties and safe exposure limits for different materials. These include:

  • Workplace Environmental Exposure Level Guides from the American Industrial Hygiene Association,
  • OSHA Permissible Exposure Levels,
  • And, Recommended Exposure Levels from the National Institute for Occupational Safety and Health.

Toxic Effects

Various organs and systems of the body can be affected by exposure to a toxic material:

  • Respiratory tract,
  • Skin,
  • Eyes,
  • Central nervous system,
  • The reproductive system,
  • Liver,
  • Kidneys,
  • Heart, and
  • Blood.

The impacts can be severe, ranging from diseases, such as cancer, to birth defects and genetic mutations affecting offspring. As you can see, exposure is a matter to take very seriously.

Medical Surveillance

Employees who have potential for exposure to contaminants that may be present at the worksite must participate in a medical surveillance program. This program is designed to qualify workers to work on-site and wear respiratory protection equipment, and to monitor for physiological changes in workers that may be related to workplace exposures. A typical medical surveillance program consists of:

  • A baseline medical exam,
  • An annual medical exam,
  • A special test relating to exposure potential,
  • And, a termination medical exam.

Medical surveillance programs may be used as a secondary means of determining if the fundamental elements of the health and safety program are working as designed, but should not be relied on as a primary means of ensuring that workers are protected while working on-site. The primary means of worker protection to potential exposure are contaminant avoidance, the effective use of PPE, and proper decontamination.

Symptom Recognition

Employees should be able to recognize signs and symptoms associated with overexposure to a hazardous material. Typical signs and symptoms of such exposure include:

  • Sudden sneezing or coughing,
  • Increased mucus,
  • Watering eyes,
  • Irritation of eyes, nose and throat,
  • Staggering or a stumbling gait, and
  • Changes in respiration.

Symptom Recognition (cont.)

Other signs and symptoms of chemical overexposure include:

  • Headache, and
  • Irritated skin or swelling. Signs of skin contact may include redness; swelling; dry, whitened skin; or itching. The skin on the hands may become dry and whitened if you wash residues off your hands with organic solvents. Repeated or prolonged contact with solvents is likely to lead to cracked and red skin or dermatitis, which can be a lifelong problem
  • Changes in normal behavior patterns,
  • Periods of dizziness,
  • Muscle spasms, and
  • Irritability.

Site Characterization

Employers are responsible for conducting a site characterization before asking employees to enter the hazardous waste site. Site characterization is an assessment that includes:

  • Location and approximate size of the site and site topography,
  • Health or physical hazards posed by hazardous materials on-site,
  • Nature of tasks to be performed,
  • Expected period of time employees will spend at the site,
  • PPE to be used for protection of workers,
  • Accessibility of the site by air or roads,
  • Possible pathways for hazardous material dispersion, and
  • Emergency personnel to provide assistance in case of an emergency.

Site Control Program

The employer must also develop a site control program to include:

  • Site map and site work zones,
  • Use of a buddy system to provide emergency assistance to affected employees,
  • Site communication,
  • Standard operating procedures for safe work practices, and
  • Identification of nearest medical assistance.

Safe Work Practices

Proper work practices can reduce employee exposure to hazardous materials and help prevent accidents. Two major strategies are:

  • Inspecting containers—any leak or corrosion that could cause a hazardous material release should be reported immediately;
  • Separating incompatible wastes on the job and in storage—never mix anything unless absolutely certain it is safe to do so;
  • And, used containers must be cleaned and tested to be sure they’re empty before reuse.

Hazardous waste should be stored away from incompatible materials in an area with an impervious floor and no cracks that could carry a hazardous material outside. Other safe work practices include:

  • Wetting down dusty operations;
  • Careful handling of hand tools or other metal objects that can spark if struck or dropped;
  • Promptly cleaning up and disposing of small spills of flammable liquids;
  • And, enforcing an absolute ban on smoking where “No Smoking” signs are posted on or around flammable materials.

Engineering Controls

Engineering controls and equipment can also help reduce the risk of hazardous wastes. Examples are:

  • Adequate ventilation to prevent buildup of gases and vapors,
  • Storage rooms that meet requirements for fire resistance,
  • Pressurized cabs or control booths on equipment, and
  • Remotely operated material-handling equipment.

PPE

Personal protective equipment, or PPE, is anything a worker can wear, carry, or use to protect against hazards encountered while doing work. Depending on the hazards at each site, PPE that may be used includes:

  • Full and partial body protective garments,
  • Protective gloves,
  • Protective footwear,
  • Protective headgear,
  • Protective face gear and eyewear,
  • Respiratory protection, and
  • Hearing protection devices.

Related equipment that may also provide protection includes:

  • Fall protection devices,
  • Communication equipment,
  • Personal flotation devices, and
  • Cooling devices.

Respiratory Protection

  • The purpose of any respirator is to protect the respiratory system from inhalation of hazards.
  • Respiratory protective devices can be categorized into two major types: air purifying respirators and atmosphere-supplying respirators.
  • And finally, fit testing to ensure a proper fit and seal checking is essential. If the respirator does not fit properly, it will do no good and potentially leave the person wearing it in grave danger.

Air Monitoring

Air monitoring instruments can provide information necessary to help site personnel determine:

  • Potential or real effects of hazardous materials on the environment;
  • Immediate and long-term risks to public health, including the health of site workers;
  • Appropriate personnel protection and respiratory equipment to be used on-site;
  • And, the actions necessary to mitigate hazards safely and effectively.

Monitoring equipment is also used to detect if an atmosphere is hazardous before or during work in an area.

To be useful in the field, air monitoring instruments need to be:

  • Portable,
  • Able to generate reliable and useful results,
  • Sensitive and selective, and
  • Inherently safe.

Related Procedures

To work safely and be sure of your responsibilities regarding hazardous wastes, it is also important that you study and understand all related procedures in force at the worksite, including:

  • Decontamination procedures,
  • The Emergency Response Plan,
  • Confined space entry procedures, and
  • The spill prevention and containment program.

Exercise

Now let’s try another exercise. Match the item in the column at left to the description at right.

Give trainees time to complete the exercise.

Here are the answers—How did you do?

  1. Fit testing is necessary for effective respiratory protection.
  2. Engineering controls use workplace features or equipment to reduce hazards.
  3. Medical surveillance is the systematic assessment and testing of a worker’s health.
  4. Site characterization is the process of assessing the worksite for features and hazards.
  5. Air monitoring is a method for ensuring that the atmosphere is not hazardous.

Questions?

At this point, be sure you understand:

  • The toxic effects of materials,
  • Symptom recognition, and
  • Protection controls.

Key Points to Remember

Slide Show Notes Here are the goals and the important takeaway points from this session:

  • Be aware of hazards and the threats they pose;
  • Know where to find information about hazards;
  • Understand medical surveillance requirements;
  • Understand work practices to minimize risk;
  • Recognize engineering controls;
  • And finally, understand and use PPE.
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